On October 1, 2026, the Department of Justice issued Directive 26-12, a memorandum to all Fraud Division personnel regarding corporate enforcement. The directive outlines corporate enforcement priorities, steps to ensure corporate investigations and enforcement actions are treated consistently, and measures to incentivize whistleblowers and corporations to voluntarily disclose improper conduct.
The directive
Firearms are among the most regulated goods in the United States, and certain firearms or firearm components have enhanced restrictions on their sale and use. Historically, silencers — accessories that suppress the sound of a firearm — were subject to strict export rules that governed items with substantial
When conducting investigations or determining whether to bring charges, the Department of Justice (DOJ) evaluates whether a company’s AI governance prevents deliberate or reckless misuse that could violate criminal law. The Securities and Exchange Commission (SEC) evaluates whether a company’s public statements about its AI capabilities are accurate and not misleading to investors. These are
The autism therapy industry is a growing target for government enforcement. As I discussed recently in Emerging Target: Federal Enforcement Comes to the Autism Therapy Industry, Applied Behavior Analysis (ABA) therapy — currently the dominant type of autism therapy — has all the markers for healthcare fraud enforcement: explosive reimbursement growth, low barriers to
Trade fraud takes center stage and continues to expand as a priority for the Department of Justice (DOJ).
On July 14, 2026, the DOJ announced its plans to expand trade fraud enforcement by creating the Global Trade & Commerce Enforcement Section (GTCES) within the DOJ’s newly formed National Fraud Enforcement Division.
Notably, this new section
Two recent settlements reached between federal antitrust authorities and antitrust defendants highlight that the federal government is open to settlements in which the defendants agree to curb allegedly anticompetitive conduct. The government publicly tallies the resolution as a win, and companies get out of tricky situations by following through on or expanding compliance initiatives already
China is increasingly on the minds of state legislators and regulators. Across the country, state legislatures and attorneys general have launched a growing wave of laws, enforcement units, and investigations targeting Chinese influence in American commerce, real estate, technology, and healthcare. The result is a rapidly expanding patchwork of state-level obligations that increasingly complements, and
On June 23, 2026, the Department of Justice (DOJ) announced the results of the 2026 National Health Care Fraud Takedown. The so-called “takedowns” have become an annual event, and this year’s involved the largest number of defendants in Takedown history. For healthcare providers and organizations, the takeaway is clear: Enforcement is nationally coordinated, increasingly data-driven
On June 10, 2026, nineteen states and the District of Columbia filed suit in the District of Maryland seeking to halt implementation of Executive Order 14398, which was issued on March 26, 2026. The order requires federal agencies to insert a mandatory contract clause into all contracts, subcontracts, and “contract-like instruments” prohibiting contractors from engaging
On May 4, 2026, the U.S. Securities and Exchange Commission (SEC) announced three settlements involving alleged violations of the beneficial ownership reporting requirements under the federal securities laws. These cases are notable in the current SEC enforcement environment because they involve non-fraud violations – what some might call “technical violations” – yet the SEC saw